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Customs Fraud Makes the Big Leagues: DOJ’s New White-Collar Priorities Confirm Heightened Risk

Last month, the Department of Justice put trade, customs, and tariff fraud squarely in the spotlight. This isn’t just another line item on the compliance checklist, it’s a loud-and-clear signal that import-related enforcement...more

A Review of Recent Whistleblower Developments - October 2023

Eleventh Circuit Adopts “Totality of the Circumstances” Test for Showing Protected Activity Under SOX and Denies Whistleblower Petition for Review - In Ronnie v. Office Depot, LLC, --- F.4th ----, 2023 WL 6210623 (11th Cir....more

OIG Special Fraud Alert on Arrangements with Telemedicine Companies

On July 20, 2022, HHS-OIG published a new Special Fraud Alert on arrangements with telemedicine companies, setting forth seven characteristics OIG believes could suggest a given arrangement poses a heighted risk of fraud and...more

New FinCEN Anti-Money Laundering Priorities

Financial Crimes Enforcement Network (FinCEN) remains committed to combating money laundering, in all forms, in connection with the banking and financial systems. To this end, on June 30, 2021, FinCEN issued new...more

The New Face of COVID-19 Fraud Enforcement: An Inter-Agency Task Force

On May 17, 2021, Attorney General Merrick Garland announced a new, inter-agency task force led by Deputy Attorney General Lisa Monaco to address fraud related to the COVID-19 pandemic (COVID-19 Task Force). According to DOJ’s...more

Five Developments Identified in Criminal and Civil Enforcement of PPP Loans

Recently, the Beverly Hills Bar Association in California sponsored a panel presentation on “PPP Enforcement Trends,” whose panelists included a high-level prosecutor from the United States Attorney’s Office and other leading...more

FinCEN Advisory and Notice on Financial Crimes Targeting COVID-19 Economic Impact Payments

On February 24, 2021, the Financial Crimes Enforcement Network (FinCEN) issued an advisory alerting financial institutions to the potential for fraud and other financial crimes related to Economic Impact Payments (EIPs) and a...more

DOJ Exercised Leniency With a Borrower Who Self-Disclosed His Error on His PPP Loan Application

Recently, the U.S. Attorney’s Office for the Eastern District of California settled a Paycheck Protection Program (“PPP”) fraud investigation with Slidebelts, Inc. and its owner Brigham Taylor not by arresting Mr. Taylor, but...more

FinCEN Issues Advisory on Cybercrime and Cyber-Enabled Crime Exploiting COVID-19

On July 30, 2020, the Financial Crimes Enforcement Network (FinCEN) issued an advisory alerting financial institutions to potential indicators of cybercrime and cyber-enabled crime observed during the COVID-19 pandemic.The...more

Roadmap to Prison: Lessons Learned from the Criminal Prosecution of Alpha Ambulance’s Leaders

No one running an ambulance company ever planned to go to prison for doing his or her job. But that is a real possibility if the government knocks on the door, and the owner or manager is dishonest in his or her response to...more

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